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On Aug. 2, 2016, the U.S. Department of the Treasury and the IRS issued proposed regulations under IRC Section 2704 (the “Proposed Regulations”) that, if enacted in its present form, might significantly curtail the ability of taxpayers to claim valuationdiscounts for both lack of control and lack of marketability in family-controlled entities.

Who has to file Form 1040NR? Form 1040NR may need to be filed if a specified individual is a nonresident alien engaged in a trade or business in the United States, represented a deceased person who would have had to file Form 1040NR, or represented an estate or trust that had to file Form 1040NR. See the form’s instructions for more information.

Have you ever wondered what will happen to the contents of your Facebook, LinkedIn, and personal e-mail accounts if you die or become incapacitated? Does your family know what accounts you have? Do they have the authority to access, use, or terminate those accounts?

This article will focus on successive changes to the federal tax code since the beginning of the 21st century—which have resulted in a dramatic paradigm shift in estate planning—as well as some of the planning strategies that have garnered increased attention as a result of those changes.

The presidential campaign is in full swing, and with it comes tax policy proposals from each candidate. Both candidates have said they will help middle class families by raising taxes on the wealthy. So what are they talking about? Who is the wealthy? How would they do that? Is it true?

American expats continue to renounce their citizenship at an increasing rate, although the overall percentage taking this step remains relatively small. Driving this trend is the fact that the United States is the sole country in the Organisation for Economic Co-operation and Development (OECD) that imposes taxes on its citizens regardless of where they reside.

Unrelated business taxable income (UBTI) is a relatively simple concept: It represents activities conducted by an organization that are both (1) commercial and (2) not in furtherance of the organization’s exempt purpose. UBTI is based on the idea that when a nonprofit participates in commercial activities or exploits its exempt purpose, it would be competing at an unfair advantage with for-profit entities because, as a nonprofit, it generally does not pay taxes on its income.

The United States and other jurisdictions have spent a decade trying to identify owners of foreign corporations. Now, a five-year-old report by the Organization for Economic Cooperation and Development (OECD) might have served as an impetus for a U.S. proposal regarding disclosure requirements for limited liability companies (LLCs).

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

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